Justia Minnesota Supreme Court Opinion Summaries

Pursuant to a plea agreement, the district court convicted Respondent of aggravated forgery. After Respondent was discharged from probation, she filed a second petition for expungement of her criminal record. The district court granted Respondent's motion to expunge her criminal records, finding that sealing Respondent's record would yield a benefit commensurate with the disadvantages to the public. The court of appeals affirmed, holding that the district court had the inherent authority to expunge Respondent's criminal records held in the executive branch. The Supreme Court reversed in part, holding that because expungement of Respondent's criminal records held in the executive branch is not necessary to the performance of a unique judicial function, the district court did not have the authority to expunge Respondent's records held in the executive branch. View "State v. M.D.T." on Justia Law

After a jury trial, Appellant was convicted of premeditated first-degree murder. The Supreme Court affirmed on direct appeal. Appellant subsequently filed a petition for postconviction relief requesting a new trial or an evidentiary hearing based on recanted testimony from a witness and newly discovered evidence. The postconviction court denied Appellant's motion on the grounds that it was untimely because it was filed after the two-year statutory limit, and no exception to the limitations applied. The court further concluded that the jury would not have reached a different outcome without the witness's testimony. The Supreme Court affirmed, holding that Appellant's petition was untimely, and Appellant failed to demonstrate he was entitled to relief under the newly discovered evidence exception to the time bar. View "Clifton v. State" on Justia Law

After a trial, Appellant was convicted of first-degree murder while committing first-degree criminal sexual conduct and was sentenced to life in prison. On appeal, Appellant challenged his conviction on several grounds but did not raise an ineffective assistance of counsel claim. The Supreme Court affirmed. Appellant subsequently filed a petition for postconviction relief, asserting a claim of ineffective assistance of trial counsel. The district court summarily denied Appellant's petition. The Supreme Court affirmed, holding that Appellant's postconviction claim was barred by application of State v. Knaffla, which provides that claims that were not raised on direct appeal or were known or should have been known but were not raised on direct appeal, are procedurally barred. View "Sontoya v. State" on Justia Law

In 2000, Appellant was indeterminately committed as a sexual dangerous person as a result of a series of sex offenses involving teenage girls. Appellant later petitioned for provisional discharge from civil commitment. After weighing the evidence presented by Appellant and the Commissioner of Human Services at a first-phase hearing, the Supreme Court Judicial Appeal Panel dismissed Appellant's petition under Minn. R. Civ. P. 41.02(b). The court of appeals affirmed. The Supreme Court reversed, holding that the Appeal Panel committed reversible error in applying Rule 41.02(b) by failing to view the evidence produced at the first-phase hearing in a light most favorable to Appellant and by weighing the evidence produced during the first phase of the hearing. Remanded. View "Coker v. Jesson" on Justia Law

Appellant was convicted of first-degree murder while committing first-degree criminal sexual conduct causing personal injury. The Supreme Court affirmed the conviction on appeal. Appellant subsequently filed a petition for postconviction relief, alleging a claim of newly discovered evidence. After an evidentiary hearing, the postconviction court denied the petition, concluding that the newly discovered evidence was not credible and, therefore, was not likely to produce a result more favorable to Appellant. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in denying Appellant's petition for postconviction relief, as the record supported the court's credibility determinations. View "Tscheu v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder, second-degree intentional murder, and second-degree unintentional murder while committing a felony. Defendant appealed, seeking a new trial based on the district court's allegedly erroneous admission of expert testimony offered by a medical examiner and a firearms examiner. Defendant argued that the testimony was improperly admitted because it intruded on the fact-finding role of the jury. Defendant did not object to the testimony at trial. The Supreme Court affirmed Defendant's convictions, holding that the district court properly admitted the expert testimony of the medical examiner and the firearms examiner. View "State v. Xiong" on Justia Law

Defendant was charged with several misdemeanor offenses, including driving a motor vehicle with a blood-alcohol concentration of 0.08 percent or more. Defendant filed a request to preserve "blood tests," but subsequently, the State destroyed Defendant's blood sample used in a blood alcohol test in accordance with its retention policy. Defendant pleaded not guilty and successfully moved to suppress the results of his blood-alcohol test. The court of appeals affirmed the district court's suppression order, adopting a per se rule requiring suppression when the State destroys evidence after a defendant has made a demand to preserve the evidence. The Supreme Court reversed, holding that the State did not violate any of the Minnesota Rules of Criminal Procedure when it destroyed Defendant's blood sample, and the district court erred in suppressing the results of the blood test. View "State v. Hawkinson" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder, first-degree intentional drive-by shooting murder, attempted first-degree premeditated murder, and attempted first-degree intentional drive-by shooting murder. Defendant filed two petitions for postconviction relief, both of which were denied. Several years after his convictions, Defendant filed a third petition for postconviction relief, arguing that the grand jury selection process in Hennepin County violated his constitutional rights to due process and equal protection. Defendant maintained that his current petition was excepted from the statutory two-year time limit. The postconviction court denied Defendant's petition for postconviction relief, concluding that the petition was time barred and that the newly-discovered-evidence exception did not apply and alternatively, that the petition was barred under the Knaffla doctrine. The Supreme Court affirmed, holding that Defendant's petition failed to satisfy an exception to the two-year limitations period, and therefore, the petition was time barred. View "Francis v. State" on Justia Law

Defendant was convicted in 1990 of first-degree premeditated murder. The Supreme Court affirmed the conviction on direct appeal. Defendant subsequently filed a petition for postconviction relief requesting an evidentiary hearing to consider evidence he asserted was new and exculpatory. Specifically, Defendant sought a hearing to consider (1) newly discovered eyewitness testimony, which he claimed buttressed his alternative-perpetrator theory, and (2) whether he was entitled to have DNA testing of a sample from a smear found at the crime scene. The postconviction court denied Defendant's petition and motion without an evidentiary hearing, concluding that Defendant did not meet the standard for receiving an evidentiary hearing. The Supreme Court affirmed, holding that Defendant failed to meet the threshold required for relief, and thus, the postconviction court did not abuse its discretion when it denied Defendant's motion without an evidentiary hearing. View "Fort v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree premeditated murder. On appeal, the Supreme Court affirmed the conviction. Appellant subsequently filed a petition for postconviction relief alleging seven separate grounds he contended warranted a new trial. The postconviction court summarily denied Appellant's petition, explaining that Appellant's claims were either meritless on their face or barred by State v. Knaffla. The Supreme Court affirmed, holding that the postconviction court properly determined that the petition and files and records of the trial conclusively showed Appellant was not entitled to postconviction relief because his claims were either meritless on their face or barred by the Knaffla rule. View "Anderson v. State" on Justia Law